The FCA has published Primary Market Bulletin 66 , together with FG26/8 and GC26/6, providing important updates for listed issuers, sponsors and advisers. The publications offer greater clarity on the FCA’s disclosure expectations while signalling areas of increasing regulatory focus ahead of the UK’s new sustainability reporting regime in 2027.
Key Developments
- FCA Finalises Technical Notes Following PMB 63
Through FG26/8, the FCA has updated its Knowledge Base and finalised amendments to:
- Technical Note 619.3: Guidelines on disclosure requirements under the Prospectus Rules: Admission to Trading on a Regulated Market (PRM) and Guidance on specialist issuers; and
- Technical Note 321.5: Working capital statements and risk factors.
These updates are intended to clarify the FCA’s expectations regarding prospectus disclosures and provide greater certainty for issuers preparing admission documents and related investor disclosures.
- Consultation on Sustainability Disclosure Guidance
Under GC26/6, the FCA is consulting on new and revised Technical Notes designed to support implementation of the UK’s new sustainability disclosure regime, which takes effect from 1 January 2027 following publication of PS26/19: Aligning listed issuers’ sustainability disclosures with international standards.
The consultation proposes:
- A new Technical Note (TN 803.1) addressing FCA expectations for “comply or explain” sustainability disclosures;
- Amendments to TN 801.4 on sustainability-related disclosures; and
- Removal of TN 802.3 relating to the previous TCFD-based disclosure framework.
The FCA is seeking feedback on the proposals until 28 October 2026.
- Preparing for the New UK Sustainability Reporting Regime
PMB 66 provides additional insight into the FCA’s expectations ahead of implementation of the new sustainability disclosure requirements.
While the new requirements do not take effect until January 2027, the FCA is signalling that preparation should begin now. Many firms may need significant enhancements to sustainability governance, data collection processes, internal controls and board oversight arrangements to support compliance with the UK Sustainability Reporting Standards (UK SRS).
Issuers should review existing governance, reporting processes, data collection arrangements and disclosure controls to assess readiness for the new regime.
- Cyber Incident Disclosure Expectations
PMB 66 also contains observations arising from the FCA’s discussions with issuers and advisers regarding disclosure obligations following cyber incidents.
As cyber-attacks continue to increase in frequency and sophistication, the FCA reminds issuers that cyber incidents are not solely an operational or IT issue. Firms should have clear procedures for assessing whether an incident could constitute inside information and trigger disclosure obligations under the UK Market Abuse Regulation. Delays or inconsistencies in escalation processes could expose firms to regulatory scrutiny.
Practical Considerations for Firms
Listed issuers and their advisers should consider:
- Reviewing the finalised prospectus-related Technical Notes;
- Assessing the impact of forthcoming sustainability disclosure requirements;
- Considering whether to respond to the FCA consultation on TN 803.1 and related guidance;
- Evaluating governance and reporting frameworks ahead of the 1 January 2027 implementation date; and
- Reviewing cyber incident response procedures and disclosure escalation processes.
Next Steps
The consultation under GC26/6 closes on 28 October 2026. The FCA is expected to finalise its sustainability disclosure guidance before the new regime comes into force on 1 January 2027.
How Complyport can help?
At Complyport, we help listed issuers, sponsors and advisers understand and implement evolving FCA disclosure requirements, ensuring governance, reporting frameworks and control environments remain aligned with regulatory expectations.
- Sustainability Disclosure Readiness: We support firms in preparing for the UK’s new sustainability disclosure regime by conducting gap analyses against the forthcoming UK Sustainability Reporting Standards (UK SRS), reviewing existing sustainability reporting frameworks and helping develop implementation roadmaps ahead of the 1 January 2027 effective date.
- Governance and Disclosure Frameworks: Our consultants assist firms in establishing robust governance arrangements around sustainability-related disclosures, including defining roles and responsibilities, enhancing board oversight, strengthening disclosure controls and implementing effective “comply or explain” assessment processes.
- Training and Regulatory Awareness: Complyport delivers bespoke training programmes designed to help boards, senior executives and operational teams navigate evolving FCA disclosure requirements. Covering sustainability reporting, disclosure governance and cyber incident escalation, our training equips staff with the knowledge and practical skills needed to identify regulatory obligations, make informed disclosure decisions and maintain ongoing compliance.
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